Is U stamp mandatory in Western Australia

[SuhyunOh]

If Pressure vessel applies ASME Sec.VIII, instead of AS 1210, is U-stamping mandatory?
Could I know where it specifically specifies in the national regulation (or DMIR publishment)?

Many thanks.

 

[DriveMeNuts]

I worked for the largest Stainless steel vessels fabricator in the southern hemisphere in New Zealand and we were fabricating and exporting ASME VIII vessels to Australia without U-Stamping.
Australian pressure equipment regulations wouldn't comment on U-stamping because that means it would then have to comment on PED for EN-13448 and all of the Quality auditing regulations for all of the worlds vessels codes.

In New Zealand and Australia you design "in general compliance" with any internationally recognised code and then quality audit the design and conduct inspections and testing using Australian regulations. PED is for Europe, U-Stamp is for USA, Aussie regulations are for Aussie.

 

[BJI]

I comes down to 'conformity assessment', refer to AS1210 Section 6 and AS3920, also refer to AS1200:2015. What is the Hazard Level for the vessel? You won't find it in the state legislation but you will be required to have a u-stamped vessel. A vessel without a stamp is almost worthless, unless you are not required to follow any recognised PE code. After fabrication, there isn't much in the way of R stamp accredited repairers so often this is not followed, but that is another can of worms.

No such thing as "in general compliance" in Australia, it might be slightly more relaxed in NZ but I would not count on it, check with the regulator first.

 

[DriveMeNuts]

In the EU, there is no need to U-Stamp an ASME VIII vessel.
The ASME vessel is designed "in general accordance" and then certified using a PED NOBO (rather than an ASME U-Stamp AI).
In exactly the same way as a British vessel is fabricated in accordance with the British PD 5500 and then audited using a PED NOBO.

Australia is no different, having their own fabrication and test auditing system.

The U-Stamp certification system is the exclusive and mandatory auditing system of the USA, which some other countries voluntarily adopt often because they don't have their own system.

 

[BJI]

DriveMeNuts, I wasn't referring to the UK/EU system at all, I will take your word for it, but I can say with certainty that you are incorrect regarding how things work in Australia. The U-Stamp system is part of the ASME code, and the ASME code is used worldwide, it is not a USA only thing. Regarding requirement for U-Stamp in the US, this comes down the individual state requirements, the same applies in Australia (and other countries), if you speak to the regulatory authorities in WA you will find that they also require a U-Stamp. As discussed, conformity assessment requires that the ASME vessel meets or exceeds the fabrication and testing requirements under Australian systems, this can't be done without using an accredited manufacturer with AI sign-off, therefore requiring a U-Stamp. So in Australia it is in full compliance to the code of construction, with additional requirements for design verification, commissioning and in-service inspection that are not equivalent under the ASME / NB system. You are free to have your own opinion on how things should be done in Australia or elsewhere, but having been involved in these processes in Australia for many years, I can speak with some authority on the subject.

 

[DriveMeNuts]

BJI.
I don't think you have any authority on this subject. "Speaking to authorities" is hardly definitive proof that a U-Stamp is required in WA. It just sounds like the authority was saying yes it is required to cover their behind because they didn't know what they were talking about.

Australia would not lower themselves to following another countries system. They are advanced and proud enough to have their own.

You sound like TTT in the following thread. All opinion and no definitive knowledge. Where is this WA regulation that specifies that WA has signed up to a foreign countries pressure vessel quality management system (i.e. U-Stamp)? TTT couldn't provide an answer either because in my first-hand experience there isn't a requirement to use U-Stamp anywhere in Australia.

[link ]

https://www.eng-tips.com/viewthread.cfm?qid=311937

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[DekDee]

FE Consulting Engineers
Design Registration and Verification of Pressure Equipment

8. Does a Pressure Vessel that has been designed to ASME BPVC Section VIII require a U-Stamp for use in Australia?

The use of a U-stamp is typically only an issue at the time of plant registration. It is not an issue at the design registration stage as the U-stamp is a physical stamp that is applied to a vessel at the completion of fabrication. Only the State of Victoria will permit the plant to operate without having a U-stamp. All other States require the full compliance to the design and fabrication Code. The ASME BPVC Section VIII specifically demands the application of the U-stamp and as such in States other than Victoria a U-stamp is required.

 

[BJI]

I don't think you have any authority on this subject. "Speaking to authorities" is hardly definitive proof that a U-Stamp is required in WA. It just sounds like the authority was saying yes it is required to cover their behind because they didn't know what they were talking about.

Actually, speaking to the regulator is probably the only definitive proof, it would always be the recommended course of action if unsure. If they won’t register the vessel without the stamp then you are out of options. By the same flawed logic, the National Board in the US also don’t know what they are talking about because they also require U-Stamps for registration? Have a look at the required marking in the ASME codes, any jurisdiction that requires full compliance to the code will require a U-Stamp, regardless of location. Always check with the state regulator first.

Australia would not lower themselves to following another countries system. They are advanced and proud enough to have their own.

It is all about following the code of construction, whatever that may be, and as discussed three times now it comes down to conformity assessment. It actually has everything to do with following the Australian system, which I have outlined in detail enough. You might be surprised by what has been proposed for the future of the Australian pressure equipment standard..

You sound like TTT in the following thread. All opinion and no definitive knowledge. Where is this WA regulation that specifies that WA has signed up to a foreign countries pressure vessel quality management system (i.e. U-Stamp)? TTT couldn't provide an answer either because in my first-hand experience there isn't a requirement to use U-Stamp anywhere in Australia.

I supplied 3 references in my first post to support the statements about conformity assessment. DekDee also supplied a reference to the FEC website, design verifiers experienced in this field. Perhaps you should read through all the references and come back with any questions, rather than dig up outdated and inaccurate opinions of others. I can definitely confirm that what TTT said was true, back around that time and before, WorkSafe WA required a U-Stamp for vessel registration. You have never worked in this field in Australia and have not supplied any references to support you position, seems more of a belligerent rant than anything useful to the OP.

 

[DekDee]

Deacon Engineers (WA)
Pressure Vessel Verification and Registration
Does a Pressure Vessel that has been designed to ASME BPVC Section VIII require a U-Stamp for use in Australia?

If a vessel is constructed to ASME BPVC Section VIII it will have a U-stamp. Non U-Stamped vessels do not meet the requirement of this code. If a vessel has been design registered based on ASME BPVC Section VIII it should be constructed to the design code and will have a U-Stamp.

 

[DriveMeNuts]

BJI, Dekdee,
You are getting confused between "Regulation" and "Discretion".

You cite large consultancy firms which use their discretion to ensure all vessels in a plant are U-Stamped. The political bodies will also use the same discretion when approving the go-ahead for a Petrochem plant. In my opinion, this is a wise use of discretion, as the U-Stamp system is proven to provide safety and reliability for such large critical plants.

My experience of designing ASME VIII vessel in Australia relates to a replacement Desalination shell and tube heat exchanger (15 metres long by 6 metres diameter) in WA. The project decision makers used their discretion to not U-Stamp. All of the auditing, inspection and testing requirements of ASME VIII were conducted. However, they were conducted by 3rd party auditors and inspectors, not by ASME accredited AI's. WA regulators used their "discretion" to accept this.

The same went for pressurised food processing vessels with a pressurised jacket for a new plant in Sydney. Discretion was used to decide not to U-Stamp. All of the requirements of ASME VIII were conducted, just to by ASME qualified AI's.

So to answer the OP's question: There is nowhere in Australia where U-Stamp is Mandatory, however there are inspection agencies and consultancy firms who insist on it and depending on the complexity of the application, will require a lot of arm twisting to change their mind. For simpler applications foregoing the U-Stamp is common. To be clear, all of the code inspection requirements are conducted by a 3rd party inspector who doesn't have ASME AI accreditation and therefore can't be U-Stamped. It is a good idea to speak with your inspection authority and learn whether they would insist on a U-Stamp for a specific application.

 

[DekDee]

DMN,
Please do not get me wrong.
I am on neither side of the arguement.
I have been involved with numerous pressure vessel projects in NZ and Australia that were manufactured "in accordance" with ASME VIII but not "in compliance" with ASME VIII utilising third party inspectors - as you noted.
I was one of those, having worked with SGS in NZ and BV in Australia.
I was just interested in the subject due to the influx of US companies in the LNG industry in Western Australia. (Apache, Chevron, Bechtel, CB&I etc).
I did a bit of research and posted what I found,
Cheers,
Shane

 

[DriveMeNuts]

Dekdee,
You have essentially repeated what I have been writing. The answer in your last post only vaguely answers its question.
I would expect that the US companies would voluntarily prefer to use U-Stamp because that is what they know works and what their vessels engineers know how to do, and that as per BJI, most state officials would encourage them to do so.
I speculate that if there was an agreement with the state government to fabricate some of the vessels domestically and there aren't a lot of U-Stamp certified fabricators, then a few less critical vessels may go down the non-compliant route. Perhaps in Victoria at least.

 

[BJI]

DMN,
The regulators rarely exercise discretion, there is no valid reason to take on the risk, and there is no PED system here that calls for additional oversight of the manufacturing process. The companies referenced are small consultancies, less than 20 people typically, who perform design verification and typically submit design registrations, but have no say in plant registration with the state regulator. There is no political or economic motive for them to write this, they are impartial, it comes down to what the government regulator will accept. Project decision makers, the inspection agencies and consultancies have absolutely no say in the matter. It doesn't even make sense, they have no vested interest in it at all, complete nonsense. The OPs question was about the practices in WA, and I can tell you it would be very rare for any discretion to be exercised, has been this way for over a decade. Like I said all along, contact the regulator and check, get approval first (if even possible), before taking bad advice and making a costly mistake.

DekDee,
Apache haven't been in Australia for some time now, but these global corporations have been around in Australia for a very long time. The biggest change is the global supply chain and diminishing heavy manufacturing in Australia. A lot of the vessels couldn't be physically built here anymore, so it is more about accommodating what the suppliers are set up for. I would assume these non-stamped examples in Australia are not recent?